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Blind spots in India's new National Action Plan on Climate Change

By Rahul Goswami

Instead of having a strongly articulated, clearly thought through vision, India’s new National Action Plan on Climate Change has a basket of eight ‘missions’ and no durable plan that will include the poorest and most vulnerable

A policy that deals with a new set of circumstances and factors needs necessarily to think differently. Climate change is not population control, not poverty, not rural unemployment. It needs to learn differently from the experiences of contemporary Indians. 

India’s new National Action Plan on Climate Change (NAPCC), framed and presented by the Prime Minister’s Council on Climate Change, displays little intent to learn differently. It desperately needed to, for climate change is not yet an emotive issue for the vast majority of Indians, whether those living in metros or Class 4 towns, whether marginal workers or IT professionals. Any policy that seeks to render convincingly into real life the hitherto abstract concerns of climate change must make communication and education a primary aim. Modern India has little time for abstractions that do not deal with inflation, the acquisitive instinct, or entertainment. The action plan, in failing to identify this obstruction, puts itself at a disadvantage from the outset. 

Instead, it has chosen as its engine a set of eight ‘missions’. Who is to ensure that these missions run synchronously? How will they integrate with each other? Will they be guided by ministries -- for the eight inspirations seem to lie very much in the schemes and politically-motivated programmes that punctuate every central administration -- or will the reins be held directly by the Prime Minister’s Council on Climate Change? The action plan provides no explanations. 

Shape and scope of the climate change plan 

India’s National Action Plan on Climate Change (NAPCC) is divided into an ‘Overview’ section and a ‘Technical Document’. The overview explains the Government of India’s thinking on the country’s economic development route, how climate change will affect that route, and what the responses could be. It states clearly: “India needs a national strategy to firstly, adapt to climate change and secondly, to further enhance the ecological sustainability of India’s development path.” 

The responses contained in the NAPCC are to be guided by a set of seven ‘Principles’ designed to “achieve a sustainable development path that simultaneously advances economic and environmental objectives”. The document’s very short ‘Approach’ speaks of “a directional shift” in India’s development route “including through the enhancement of the current and planned programmes”. A number of these programmes exist already under various ministry initiatives, while others are suggested in the NAPCC’s ‘Technical Document’ which forms the bulk of the plan. 

The core of the NAPCC consists of eight ‘Missions’. These represent “multi-pronged, long-term and integrated strategies for achieving key goals in the context of climate change”. The plan makes the qualification that several of the programmes contained in the missions are already part of current actions by several central ministries and departments. The missions are: National Solar Mission, National Mission for Enhanced Energy Efficiency, National Mission on Sustainable Habitat, National Water Mission, National Mission for Sustaining the Himalayan Ecosystem, National Mission for a Green India, National Mission for Sustainable Agriculture, and National Mission on Strategic Knowledge for Climate Change. Each mission will be tasked to evolve specific objectives spanning the remaining years of the Eleventh Plan (until 2012) and Twelfth Plan periods (2012-2017). 

Mentioning that awareness-building is vital for implementation of the NAPCC, the ‘Implementation’ section of the document says that the plan administrators “will develop appropriate technologies to measure progress in actions being taken in terms of avoided emissions, wherever applicable, with reference to business-as-usual scenarios”.

In the ‘Institutional Arrangements’ section of the plan document, the need for an advisory council on climate change, chaired by the prime minister, is explained. This council has “broad-based representation from key stakeholders, including government, industry and civil society and sets out broad directions for national actions in respect of climate change”. 

The ‘Technical Document’ of the NAPCC begins with a background on India’s action plan and invokes the findings of the Fourth Assessment Report of the Intergovernmental Panel on Climate Change (IPCC). This section explains the imperative for poverty alleviation, the relationship between the human development index and energy consumption, and also outlines some observed changes in climate and weather events in India and their impacts on key sectors such as agriculture. Actions for adaptation and mitigation are suggested, before the technical document sets out more detailed schema for the eight missions. These include current conditions, regulatory and policy environment, changes required in view of the NAPCC, financing and risk considerations, and awareness, outreach and capacity-building measures. 

‘Other Initiatives’ occupies a large chunk of the remainder of the document, after the eight missions are explained. These initiatives explain the need for greenhouse gas (GHG) mitigation in power-generation, for renewable energy technologies, for disaster management responses to extreme climate events, protection of coastal areas, and creating appropriate capacity at different levels of government.  

Finally, a short section on the international dimension of climate change includes India’s participation in the multilateral processes under the United Nations Framework Convention on Climate Change (UNFCCC) and the Kyoto Protocol. The section rounds off with a discussion on the Clean Development Mechanism (CDM) and its use in the Indian industrial environment. 

Why is India’s climate change direction deemed as best being served by missions whose descriptions contain no linkages? A critical reading of the action plan reveals that its assumptions are couched in a worryingly familiar framework -- the same way that health, education and livelihoods never meet in any state’s policy effort. Moreover, the plan assumes that individual mission objectives will be delivered with the inclusion of “public-private partnerships and civil society action”. Again, this is an assumption that has been soundly disproved in the last three years by Indian society in every state that has seen revolts against the ruling economic ideology. How then can this council posit that such a combination will deliver long-term sustainability and help mitigate the impact of climate change in India?  

CO2 emissions from the consumption of fossil fuels  
Top ten countries - (Million Metric Tons of Carbon Dioxide)  
2005 1995 1985 rank
USA 5,956.98 USA 5,289.26 USA 4,577.58 1
China 5,322.69 China 2,844.56 Former USSR 3,496.77 2
Russia 1,696.00 Russia 1,622.94 China 1,838.47 3
Japan 1,230.36 Japan 1,075.50 Japan 887.44 4
India 1,165.72 Germany 876.75 Germany, West 689.20 5
Germany 844.17 India 862.18 Britain 588.25 6
Canada 631.26 Britain 555.85 India 440.37 7
Britain 577.17 Canada 505.88 Canada 433.37 8
S Korea 499.63 Italy 427.93 Poland 418.54 9
Italy 466.64 Ukraine 418.26 France 388.92 10
Source: Energy Information Administration, US Department of Energy 

The action plan contains -- in its overview, principles, approach and mission summary sections -- a good dose of the concerned international language of climate change recognition. The audience for such a language may exist in the contingents that throng G8 meetings, the World Economic Forum and global roadshows to promote India’s economic attractiveness, but they will remain incomprehensible to tens of millions in our towns and cities, our tehsils and our talukas. Who will take on the responsibility for its interpretation and translation? Will it be the ‘strategic knowledge’ mission? We are not told. 

Amongst the 35 urban agglomerations and cities in India with populations of over 1 million are Allahabad, Amritsar, Asansol, Dhanbad, Faridabad, Jabalpur, Jamshedpur, Nashik, Rajkot and Vijayawada. How will the action plan reach the citizens of these cities? How will these cities’ municipal corporations and councils be sensitised, trained, motivated and equipped to transmit the plan message to every city ward? Who will fund this massive national outreach without which India’s climate change programme will fail? Will it be city administrations, state governments, or the central government? These concerns will immediately be felt by urban governance officials when the NAPCC gets into gear. But they are left unanswered in the plan. 

Although the action plan is deficient on a number of counts, everyone agrees that a national action plan is of prime importance to an India that has wedded itself to the idea of 9% annual GDP growth in the foreseeable future. But how are the urban poor to become rights-holders (not stakeholders) in a future that includes climate change mitigation and local sustainable development? Will the 8.2% of Vadodara’s population that lives in the slums be heard and included? Will the 12.5% of Varanasi’s; the 15% of Jaipur’s; the 19% of Delhi’s; the 21% of Pune’s; the 43.8% of Meerut’s; and the 49% of Mumbai’s population? 

The NAPCC does not consider whether the urban poor will ever be reached by renewable energy technologies. The plan will first have to deal with the country’s established power bureaucracies -- a difficult task -- and the consequences of not doing so lie outside the concerns stated in the NAPCC. But it will still have an impact on India’s climate change burden.

Consider the carbon footprint of the National Thermal Power Corporation -- India’s largest power company. NTPC’s annual emissions for 2006-07 are 168.7 million metric tonnes, a calculation recently publicised through reports in the Carbon Monitoring for Action (CARMA) database on the global power industry. The company has a total power-generation capacity of around 29,000 MW, of which 86% is coal-based -- NTPC is the largest consumer of coal in India, needing 125 million tonnes to run its power plants. The company plans to add 21,941 MW of new generating capacity between now and 2012; of that, 15,180 MW will be through coal-fired plants and the rest from gas- and water-based projects. 

According to NTPC, it is “among the most efficient producers of power using fossil fuels, emitting only 800 grams of CO2 per kwh of electricity generation”. Although power sector experts and independent emissions analysts may argue with this claim, it is as misleading as repeating that India’s power sector emissions are only 6% of the USA’s and just 25% of China’s. The consideration that our per capita emissions will only increase, and that India’s share of global emissions will also only rise, must be central to our development direction and our commitment to finance clean technology and combat climate change. That commitment over the next few decades must be linked with today’s truth -- that, no matter how efficiently we burn coal, it can only lead to disaster. 

In its report, ‘Integrated Energy Policy’, the Indian Planning Commission projects that electricity-generation in India in the next 25 years will increase up to eight times; that this will require an enormous rise in our use of coal (up to four times as much) and up to 10 times our current use of natural gas. M V Ramana and Divya Badami Rao of the Centre for Interdisciplinary Studies in Environment and Development, in Bangalore, warn in the Bulletin of the Atomic Scientists that such an energy direction will propel India’s per capita emissions up to 3.6-5.5 tonnes of CO2 by 2030. 

Personal transport in the absence of public transport options, residential use in fast-urbanising settlement zones, and small to medium industry are some of the prominent challenges for the NAPCC. Over the past decade, transport’s greenhouse gas emissions have increased at a faster rate than any other energy-using sector. China, through a nationwide directive issued by the Ministry of Construction, in 2006, accords top priority to developing urban public transportation. India’s National Urban Transport Policy 2006 calls upon the Indian states to focus on the mobility of people rather than of automobiles, and promote public transport in order to reduce fuel consumption and emissions, including emissions of greenhouse gases. 

And there is a desperate need to. The IPCC predicts that the world’s fastest increases in transport energy use will occur in developing countries. S Sundar and Chhavi Dhingra of The Energy and Resources Institute (TERI), New Delhi, point out that these countries, led by India and China, are projected to account for much of the future growth in oil consumption and GHG emissions due to their strong economic and population growth. The International Energy Agency’s projections of annual CO2 growth rates for 2002–2030 range from 1.3% for the OECD nations to 3.6% for developing countries. According to the Asian Development Bank (ADB), China’s energy use for transportation is projected to grow by 6-9% per year, while India’s is expected to grow at 5-8% a year between now and 2025. The ADB projects CO2 emissions from on-road transport in China and India to increase 3.4 times and 5.8 times respectively, over a 30-year period (2005-2035). 

Yet, from the conventional more-GDP-is-better point of view, India faces a funding shortfall of Rs 451,000 crore in reaching its target of adding 78,577 MW of power-generation capacity in 2007-12, which will require Rs 1.03 million crore by current estimates. Demand projections made in the 16th Electric Power Survey are seen as critical: over 100,000 MW of additional generation capacity needs to be added by 2012 to bridge the gap between demand and supply of power.

Public sector power generation -- CO2 emissions in million tonnes
  2006-07 2005-06 2004-05 2003-04 2002-03 2001-02 2000-01
North 129.55 120.1 112.21 110 106.81 102.74 97.87
East 96.36 92.52 83.96 75.51 66.59 61.43 58.03
South 109.25 101.76 105.6 108.12 105.24 92.18 89.02
West 157.72 153.93 157.78 144.13 148.56 141.6 135.19
Northeast 2.65 2.53 2.47 2.46 2.29 2.16 2.21
India 495.54 470.85 462.02 440.22 429.48 400.11 382.31
Source: Central Electricity Authority's CO2 baseline database 

It is against this that the NAPCC will face its sternest test, for the power bureaucracies (and their finance overlords) are strong. Consider how the Ministry of Power’s ‘Blueprint for Power Sector Development’ (2001) approaches the question of energy provision. The document is dated 2001 but is still used as justification for massive planned increases in the use of coal as a primary fuel: “The capacity addition targets of 6,400 MW through nuclear power and 10,700 MW through non-conventional resources have been accordingly fixed for the period up to 2012. The large coal reserves in the country provide a ready and economical resource and ensure energy security. Hence, coal has been identified as the mainstay fuel for power generation till 2012. Emphasis has been laid on setting up large pit head stations to avoid the high costs associated with transportation of high-ash-bearing Indian coal and overstraining the already stretched rail network.” 

What of industry, the largest consumer of commercial energy in India? This sector accounted for 42% of the country’s total commercial energy during 2004-05, and for a third of its total CO2 emissions. How have its responsibilities and duties been defined by the action plan? Only marginally, and even there with data and an outlook that predate the new industrial-services push of the last five years. “The CO2 emissions from the industrial sector can be broadly categorised into two heads,” says the plan, “process-related emissions, and emissions due to fuel combustion in industries. Of the total estimated 250 million tonnes of direct CO2 emissions from industry in 1994, nearly 60% were accounted for by energy use”. What of the now? What of the forecasts beyond 2012 and post-Kyoto Protocol options? When a handful of industries are making their own assessments for such a future, the plan finds no need to. Why the glaring absence of supporting material even in the ‘technical’ part of the action plan? 

It is a deficiency that runs through the entire document. There are worthy examples elsewhere of national outreach, which this action plan could have referenced. Perhaps it did not because its genesis and construction have been hidden from the very people it professes to help -- the citizens of India. Drafts of several important new policies, like the new environment policy, have been released to the public with an invitation for suggestions, objections and comments. There have also been consultations during the framing of some of these policies, even if these were more cosmetic than sincere. The National Action Plan on Climate Change has, in contrast, emerged from behind a curtain of policymaking secrecy and we are given no information as to whether the opinions of a broader community of experts, or of concerned citizens’ groups, were sought during its drafting. 

In Cuba, hurricane and disaster risk reduction is taught in schools and training is carried out for the entire population, every year. Important public awareness activities include linking research to policymaking, with an emphasis on getting research messages out to appropriate target groups, building the credibility of forecasts and improving their dissemination and use. The National Mission on Strategic Knowledge for Climate Change, the eighth of the NAPCC’s missions, contains a draft blueprint for national activity of a similar scope in India, with climate change as its deliverable. But the framework stops short at defining systems that will convert the blueprint into communication.

Where data is concerned, our neighbour China has in place a systematic observation network through which it monitors atmospheric composition, energy balance, water and carbon cycles, ecosystems, land use, and ice and snow cover. The country regularly submits real-time observation data and historical data records from national stations to the World Data Centre for Meteorology. China’s eastern provinces are arguably the most intense greenhouse gas emitters in the world. But the country also has an operational system of short-term climatic monitoring, prediction and assessment established in the Beijing Climate Centre, and runs regional cooperative climate programmes with other Asian countries such as Iran, Nepal, Sri Lanka and Uzbekistan. 

In its current form, India’s new action plan has neither a South Asian outlook, nor an Asian concern, and certainly no global view. It says little of substance about the international deadlock in the climate arena and is coy about what it expects from industrialised countries. There is no attempt made to situate an Indian approach to development within the constraints of a changing climate, because such an attempt requires a forthright internationalist approach to be outlined, if not explained through both policy and realpolitik. Thus, there is no call for the responsibilities of industrialised countries to exceed their existing commitments to the Kyoto Protocol or a reiteration of targets. 

The absence of a strongly articulated, clearly thought through vision that encompasses the global, regional, national and local is precisely why we have been presented with a basket of eight missions and not a durable plan that will include the poorest and most vulnerable. The intention of the action plan is to “further enhance the ecological sustainability of India’s development path”. But it ignores the host of questions that are being raised every day about the relevance of environmental economic approaches to development challenges and poverty reduction. 

There are references enough to “renewable energy technologies” in the action plan, and to “sustainable development”. Without a lucid and accessible explanation of why such technologies and such practices must replace our conventional approach, the NAPCC will stay an agenda that has no follow-through. In the early-2000s, Amulya K N Reddy, an energy economist, explained that “sustainable development is often given lip service by the country’s spokesmen at international conferences, but, within the country, there are no political and economic instruments for its implementation”. He added: “Worse still, following some industrialised country interpretations, sustainable development is often equated with environmentally sound development, ignoring its equity and empowerment (self-reliance) dimensions.”

These are only a few of the large conceptual and communication gaps in the NAPCC. As long as they exist, how will the plan ever deliver “a directional shift in the development pathway”? After all, India produces 846,000 barrels of oil a day (2006 estimate) and consumes 2.63 million barrels a day. The analytical underpinnings of such a wide-ranging plan are incomplete, and as long as they remain so there is no scope for a genuinely indigenous and equitable Indian approach to re-framing development within the ambit of the changing global climate. The action plan fails to recognise -- even though it refers to several earlier policies and regulations -- that a sectoral and ministry-bound approach to the problem has, to date, ensured that climate change risks are kept out of national development policies.

This obstinacy limits the action plan, especially in areas where it needs to be most forthright. The plan warns that climatic vagaries constitute a palpable threat to agricultural productivity, crop yields, and farm-level agricultural revenues, but it does not assemble knowledge or recommendations for adaptation. The plan ignores concerns that exist at a level more basic than that of climate change: that nearly two-thirds of India’s total cultivated area is drought-prone, and nearly 40 million hectares of land area are flood-prone. What will climate change do to agriculture in these zones? We are not told. We also know that a mean sea level rise of 46-59 cm has been projected along India’s coast by the end of the century, with a 15% increase in the intensity of tropical cyclones. What will this mean for the 250 million people who live within 50 km of India’s 7,500 kilometres of coast? What will it mean for our 3,638 fishing villages? We are not told. If there is to be a Version 2 of the NAPCC -- consultative, far more representative of stressed communities, and with targets -- it must follow immediately for India to respond meaningfully to climate change.

(Rahul Goswami is an independent journalist and researcher based in Goa) 

InfoChange News & Features, September 2008